Assistant Eula Bingham has asked me to respond to your letter dated February
8, 1980, requesting a permanent variance from Section 1910.217(c)(1)(i)
Mechanical Power Presses - Point of Operation Guarding, of the Occupational
Safety and Health Standards.

You have stated that you operate mechanical power presses to size the ends
of metal tubing. These tubes range from approximately 10" to 50" in length
and from approximately 1-1/2" to 5" in diameter. You further state that the
point of operation on your presses are currently guarded on all sides by hair
pin guards. You insert the tubes to be sized into an opening in the hair pin
guard which is slightly larger than the diameter of the material being fed.
The opening is approximately 7- 1/2" to 9-1/2" from the point of operation
depending on the press. You have requested a variance on the basis that the
opening on your hair pin guard to insert the material does not meet the time
and distance requirements of Table 0-10 of the standard.

OSHA Program Directive STP 1-12.21, Mechanical Power Presses authorizes in
Section 4.b. a guard or fixed barrier attached to the frame, die, or base of
a press and prevents the operator from putting his hands or fingers into the
point of operation even when the press is not cycling (copy enclosed). If
your hair pin guard is attached to the frame and fully encloses the point of
operation (danger zone) and the opening is adjustable to the size of the
material being fed to the press and the adjustable guard returns to the
closed position when the material is removed from the press, you will be
meeting the intent of Section 1910.217(c)(1)(i). Therefore, a variance is
unnecessary.

Affected employees and their authorized representatives shall be informed of
this clarification in the same manner they were informed of your request for
a variance.

Our Madison District Office is in agreement with this clarification. Any
further questions concerning the matter should be directed to Robert Levand,
District Supervisor, U.S. Department of Labor - OSHA, Suite 270, 2934 Fish
Hatchery Road, Madison, Wisconsin 53713.

No further action will be taken on your request for a variance. If I can be
of further assistance, please contact my office at (202) 523-7144.

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